How have the courts dealt with a dispute between an architectural committee of a homeowners association and a homeowner's association?

In Ruiz, the architectural committee of a homeowners association denied a husband and wife's request for approval of their plans to build a new house. (Ruiz v. Harbor View Community Assn., supra, 134 Cal.App.4th at p. 1462.) Thereafter, the husband accused the committee of making arbitrary and capricious decisions, of failing to apply its guidelines consistently, and of applying its own subjective preferences. (Id. at p. 1463.) He made various requests for information and documents. (Ibid.) In response, the attorney for the association wrote two letters that the husband claimed were defamatory; in addition to addressing the husband's charges against the association, he accused the husband of "reprehensible conduct" at an association board meeting (id. at pp. 1463-1464) and of "harassing" and "virtually stalking" the directors at association board meetings (id. at pp. 1464-1465).

The appellate court held that the attorney's statements concerned an issue of public interest. (Ruiz v. Harbor View Community Assn., supra, 134 Cal.App.4th at pp. 1468-1470.) "Plaintiffs and [the association] were involved in ongoing disputes over approval of Plaintiffs' . . . plans, the application of [the association]'s architectural guidelines, and Plaintiffs' demands for information and documents. Those disputes were of interest to a definable portion of the public, namely, the members of [the association], because they would be affected by the outcome of those disputes and would have a stake in [association] governance. [The husband's] conduct at [the association] board meetings

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